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Internet "Indecency" Stipulation


                   UNITED STATES DISTRICT COURT
                 EASTERN DISTRICT OF PENNSYLVANIA

________________________________________
                                         )
AMERICAN CIVIL LIBERTIES UNION, et al.,  )
                                         )
            Plaintiffs,                  )
                                         )
                  v.                     )   Civ. No.96-0963 
                                         )
JANET RENO, in her official capacity as  )
ATTORNEY GENERAL OF THE UNITED STATES,   )
                                         )
             Defendant.                  )
                                         )
_________________________________________)

                            STIPULATION

	At the request of the three-judge Court convened in this case 
under 28 U.S.C. Sec. 2284, and for the purpose of assisting the 
Court in establishing a more orderly schedule for conducting a 
hearing on Plaintiffs' Motion for Preliminary Injunction, the 
parties, through their undersigned counsel, hereby stipulate and 
agree as follows:

	1. Plaintiffs will present evidence in support of their 
Motion for Preliminary Injunction on March 21, and 22, 1996 (with 
April 1, 1996, available if necessary to conclude plaintiffs' 
case, or another date to be agreed upon by the parties or set by 
the Court).

	2. Defendant will present her evidence in opposition to 
Plaintiffs' Motion for Preliminary Injunction on April 11 and 12, 
1996.  Plaintiffs may seek permission for limited rebuttal.

	3. In accordance with the Memorandum Opinion and Order of the 
Court on February 15, 1996, the Temporary Restraining Order as 
previously granted remains in force until the three-judge Court 
hears Plaintiffs' Motion for Preliminary Injunction in accordance 
with the foregoing schedule and has decided the motion.

	4. The defendant stipulates that she will not initiate any 
investigations or prosecutions for violations of 47 U.S.C. Sec. 
223(d) for conduct occurring after enactment of this provision 
until the three-judge Court hears Plaintiffs' Motion for 
Preliminary Injunction in accordance with the foregoing schedule 
and has decided the motion.  To the extent legally permitted, 
defendant retains her full authority to investigate or prosecute 
any violation of Sec. 223(a)(1)(B), as amended, and Sec. 223(d) as 
to conduct which occurs or occurred during any period of time 
after enactment of these provisions (including for the period of 
time to which this stipulation applies) should the Court deny 
plaintiffs' motion, or if the motion is granted, should these 
provisions ultimately be upheld.

	5. This stipulation does not extend to or restrict any action 
by the United States in connection with any investigations or 
prosecutions concerning child pornography or concerning any 
communication, material, or information that is obscene.


FOR THE DEFENDANT

FRANK W. HUNGER
Assistant Attorney General
Civil Division

MICHAEL R. STILES
United States Attorney

MARK R. KMETZ
Assistant United States Attorney

DENNIS G. LINDER
Director, Federal Programs Branch

THEODORE C. HIRT
Assistant Branch Director

ANTHONY J. COPPOLINO
JASON R. BARON
MARY E. KOSTEL
JAMES E. GILLIGAN
Trial Attorneys
United States Department of Justice
Civil Division
Federal Programs Branch
901 E. Street N.W.
Washington, D.C. 20530
Tel: (202) 514-4782


FOR THE PLAINTIFFS

CHRISTOPHER A. HANSEN
MARJORIE HEINS
ANN BEESON
STEVEN R. SHAPIRO
American Civil Liberties Union Fdn.
132 West 43rd St.
New York, NY 10036
212-944-9800

STEFAN PRESSER
ACLU of Pennsylvania
125 South Ninth St., Suite 701
Philadelphia, PA 19107
215-923-4357

LAURA K. ABEL
CATHERINE WEISS
Reproductive Freedom Project
American Civil Liberties Union Fdn.
132 West 43 St.
New York, NY 10036
212-944-9800

DAVID L. SOBEL
MARC ROTENBERG
Electronic Privacy Information Center
666 Pennsylvania Ave. SE, Suite 301
Washington, D.C. 20003
202-544-9240

MICHAEL GODWIN
Electronic Frontier Foundation
1550 Bryant St., Suite 725
San Francisco, CA 941103
415-436-9333

ROGER EVANS
Legal Action for Reproductive Rights
Planned Parenthood Federation Of America
810 Seventh Avenue
New York, New York 10019
(212) 261-4708


                     *     *     *


SO ORDERED this ___ day of February, 1996.


BY THE COURT:





________________________________________
STEWART DALZELL
United States District Court


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